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BODDY v. COMMISSIONER

Docket No. 22710-80.

47 T.C.M. 1381 (1984)

T.C. Memo. 1984-156

A.E. and Brenda L. Boddy v. Commissioner.

United States Tax Court.

Filed March 29, 1984.

Attorney(s) appearing for the Case

John M. Bovis, 53 Perimeter Center East, Atlanta, Ga., and William E. Frantz, 3390 Peachtree Rd., Atlanta, Ga., for the petitioners. David D. Aughtry, for the respondent.

Memorandum Findings of Fact and Opinion

WILES, Judge:

Respondent determined the following deficiencies in petitioners' Federal income taxes:

  Taxable Year               Deficiency

     1976 ................... $13,307
     1977 ...................  23,044

The sole issue for decision is whether petitioners' Arabian horse-breeding operation was an "activity * * * not engaged in for profit" within the meaning of section 183(a)....

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